https://www.taxtmi.com/caselaws?id=258696 Reimbursement of actual head office technical expenditure, where no technical knowledge or services were made available, was not taxable as fees for technical services under the applicable India-France treaty. As the payment was not chargeable to tax in India and was in substance a transfer within the head office-branch relationship, no tax deduction obligation arose. The corresponding disallowance under section 40(a)(ia) therefore could not be sustained, and the addition was deleted. en-us Tue, 16 Dec 2014 00:00:00 +0530 Fri, 17 Apr 2015 14:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258696 Reimbursement of actual head office technical expenditure, where no technical knowledge or services were made available, was not taxable as fees for technical services under the applicable India-France treaty. As the payment was not chargeable to tax in India and was in substance a transfer within the head office-branch relationship, no tax deduction obligation arose. The corresponding disallowance under section 40(a)(ia) therefore could not be sustained, and the addition was deleted. Case-Laws Income Tax Tue, 16 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258696